Direct Implementation of OECD Guidance
January 1, 2025

Direct Implementation of OECD Guidance
Italy's approach to transfer pricing in 2025 is firmly based on Art. 110(7) of the Italian Income Tax Code and incorporates the full arm's length principle, taking direct reference from the 2022 OECD Guidelines. All transfer pricing arrangements between associated enterprises must reflect market terms as independent parties would agree.
Sources:
OECD Transfer Pricing Guidelines 2022 OECD Country Profile: Italy